LIHTC Market Study Requirements in Massachusetts

The agency & primary document

Allocating agency

Executive Office of Housing and Livable Communities (EOHLC / 'HLC'); 4% bond credits via MassHousing / MassDevelopment

QAP / guidelines

https://www.mass.gov/info-details/qualified-allocation-plan

Governing document

2025-2026 Qualified Allocation Plan — market-study requirements are in the QAP body (no separate guideline); submitted through OneStop+

Methodology

NCHMA Model Content Standards

Required market study sections

Massachusetts market studies follow the NCHMA Model Content Standards. The required sections are:

• Executive Summary — Concise summary of each section including data, analysis, and conclusions. 11 minimum content items including feasibility opinion, strengths/weaknesses, absorption estimate.
• Introduction and Scope of Work — Purpose, intended use, intended users, scope of work, effective date, physical inspection date.
• Project Description — Unit mix, utilities, target market, unit and community amenities, construction date. If rehab: scope of work, existing rents and vacancies.
• Location — Site description, site photos/maps, community services map, neighborhood evaluation (visibility, accessibility, crime).
• Market Area Definition — PMA description and rationale, PMA map. Extended/secondary market area if applicable.
• Employment and Economy — Employment trends, employment by sector, unemployment rates, major employers and proximity, planned expansions/reductions.
• Demographic Characteristics — Population and household estimates/projections, building permits, household characteristics (income, tenure, size). Senior/special needs: target-market data.
• Competitive Environment — Comparable profiles and photos, map of comps, vacancy and rents analysis, subject comparison, affordable housing alternatives, pipeline projects.
• Affordability Analysis, Demand Analysis, Capture Rates, and Penetration Rates — Demand estimate, affordability analysis, capture rate, penetration rate.
• Local Perspective of Rental Housing Market and Housing Alternatives — NEW in MCS 3.1 (September 2025). Local market context and housing alternatives beyond standard comparable analysis.
• Analysis / Conclusions — Absorption rate and lease-up timeline, market feasibility statement, strengths and weaknesses, key conclusions reconciling any conflicting indicators, recommendations if any.
• Other Requirements — Analyst qualifications, data sources, physical inspection date, limiting conditions, signed certification.

Key Massachusetts rules

Massachusetts-specific overlays

• Analyst must be a non-related, HLC-approved party at developer expense
• NCHMA membership accepted as the analyst qualification standard
• HLC conducts its own independent marketability evaluation and uses Section 8 contract rents in feasibility testing
• Income-tiering proposals must be specifically addressed in the study
• HLC may compel a new study if it deems one inadequate

Required companion documents

• Market study within the OneStop+ application (non-related, HLC-approved analyst, at developer expense)
• Sponsor's comparables and competitiveness analysis
• For local housing-need claims: municipal consolidated plan / local affordable housing plan

Things analysts miss in Massachusetts

• The QAP's '>30% rent burden' is a community eligibility/scoring threshold, NOT a market-study affordability assumption — do not conflate
• Agency is officially EOHLC but 'HLC' in-text; older docs say 'DHCD'. mass.gov blocks automated fetching (403)

Frequently asked questions

Who reviews LIHTC market studies in Massachusetts?

Executive Office of Housing and Livable Communities (EOHLC / 'HLC'); 4% bond credits via MassHousing / MassDevelopment sets the market study requirements and reviews submissions for Massachusetts Low-Income Housing Tax Credit applications.

How current must a Massachusetts LIHTC market study be?

Not specified in the QAP (no maximum study age stated) — verify with HLC

Does Massachusetts follow NCHMA standards?

Massachusetts market studies follow the NCHMA Model Content Standards section structure — NCHMA-deferring. The QAP names and links the NCHMA Model Content Standards, accepts NCHMA membership as analyst qualification, and strongly encourages NCHMA-consistent studies. HLC also runs its own independent marketability evaluation..

Other states

See all 51 states →

This summary is for general reference and reflects Executive Office of Housing and Livable Communities (EOHLC / 'HLC'); 4% bond credits via MassHousing / MassDevelopment's published guidance as understood by StudyScribe; it is not legal or compliance advice. Always confirm requirements against the current QAP / market study guidelines before submission.